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CASE NO. 08-CIV-80893 MARR/JOHNSON
JANE DOE,
Plaintiff,
vs.
Defendant.
/
Tuesday, June 15, 2010
4:06 p.m.
Taken before ELAINE CRANDALL, Registered
Professional Reporter and Notary Public in and for
the State of Florida at Large, pursuant to Notice
of Taking Unsworn Statement in the above cause.
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APPEARANCES
LEHRMAN
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301-3268
ALSO PRESENT:
MICHAEL FISTEN
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Thereupon--
was called as a witness by the Plaintiff and,
after having been first duly sworn, was examined
and testified as follows:
BY MR. EDWARDS:
Q.
Tell us your name.
A.
Q.
And just to the get to the point, you
know who Jeffrey Epstein is?
A.
Yes.
Q.
And you've met him before?
A.
Yes.
Q.
And you know who Jean-Luc Brunel is?
A.
Yes.
Q.
And you have met him before?
A.
Yes.
Q.
Which one did you meet first?
A.
Jean-Luc Brunel.
Q.
And where did you meet him?
A.
In Miami Beach.
Q.
When?
A.
In 1998.
Q.
And how?
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A.
In his office.
Q.
Related to what; modeling?
A.
Working, yeah. Modeling.
Q.
What, at that point in time, did you
know about Jean-Luc Brunel?
A.
Nothing. At that time I didn't know
anything.
Q.
So how did you meet with Jean-Luc Brunel
in his office in 1998?
A.
Because there was a gentleman from
Switzerland who wanted to make business with them.
And I was hired by that gentleman to look through
all the accounts to make sure that -- you know,
they were kind of in bankruptcy. But he wanted to
know that his money, his investment, would be
good. So that's why I went. Like, an external
audit to do -- to see what was the income, the
expenses and something like that.
Q.
Who is the guy from Switzerland?
A.
I'm not going to tell you his name.
Q.
Is that somebody who is still in touch
with Jean-Luc Brunel?
A.
No. Not at all.
Q.
What's the reason for not wanting to
disclose his name? Does he have anything to do
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with this case?
A.
No. But I don't have permission. I
have to ask him.
Q.
Okay. And after your meeting with
Jean-Luc Brunel in 1998 -- well, what company was
Jean-Luc Brunel with then?
A.
Models, it was, at that time.
Q.
K-A-R-I-N?
A.
Yes.
Q.
And is that the only other modeling
agency that you have known Jean-Luc Brunel to be
associated with, besides MC Squared?
A.
Yes.
Q.
And how long was Jean-Luc with
from 1998 through --
A.
No, Jean-Luc was the owner of
Before that.
Q.
I think since 1986, in Paris.
All right. And why was he no longer
affiliated with
at some point in time?
A.
He closed -- he -- how you say -- he
made a dissolution. He dissolved the company.
Q.
Were you ever hired to work with
A.
I was hired to work with
Q.
When was that?
A.
In 1998.
, yeah.
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Q.
What was your position?
A.
At that time, bookkeeper.
Q.
In Miami?
A.
Yes.
Q.
And how long did you stay as the
bookkeeper in Miami for
A.
Until 2003, when they changed the
company to MC Squared.
Q.
So when did the official change come
from
to MC Squared?
A.
In 2003.
Q.
And when is the first time you met
Jeffrey Epstein?
A.
I met Jeffrey Epstein only once in my
life. And I believe it was in 2003. Two
thousand -- yeah, by the end of 2003, 2004.
Q.
Where?
A.
In New York.
Q.
What was the occasion?
A.
It was the open party for MC Squared.
Q.
Where was that held?
A.
In a discotheque in Manhattan.
Q.
What discotheque?
A.
I don't know. I don't remember.
Q.
And did you meet Elaine Maxwell?
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A.
I don't know her name. But he was
with -- with a woman. I don't know.
Q.
And what is your understanding or what
was your understanding that Jeffrey -- in terms of
Jeffrey Epstein's involvement with MC Squared?
A.
Jean-Luc always said that Jeffrey was
his friend, that he is a millionaire. And that
Jeffrey was giving him the money to -- you know,
loans or whatever -- and the apartments for the
girls and things like that.
Q.
All right. Let's break that down.
Giving money for what purpose? For furthering MC
Squared?
A.
For -- for -- yeah, the money came to MC
Squared, not to -- I don't know. Prior to 2003, I
don't know if Jeffrey Epstein ever gave him money.
I know that from the longest Jean-Luc was living
in an apartment that belongs to Jeffrey Epstein
Q.
What apartment is that?
A.
It's in New York. I don't know the
address.
Q.
Is that at 301 East 66th Street?
A.
Yeah, something like that. I think it's
that one.
Q.
And it's my understanding that Jeffrey
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Epstein owns or controls numerous apartments in
that -- at that same address; is that right?
A.
Yes. Yes.
Q.
And have you ever been to that address?
A.
No.
Q.
And how do you know that he owns or
controls numerous apartments at that address?
A.
Because at that time
Valenzeula
was the office manager of the new and she was
dealing personally with the assistant of Jeffrey
Epstein. And she had to do the payments for the
cable and, I believe, electricity.
Q.
And
Jeffrey Epstein that
was dealing with?
A.
I don't know.
Q.
A.
I believe so.
Q.
Do you remember that name?
A.
Yes.
Q.
That's somebody who no longer lives
here, right?
A.
I -- I believe I heard that, yeah.
Q.
A.
who was the assistant of
Who did you hear that from?
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Q.
Okay. And at some point in time you
came to know that the models were also staying in
these apartments at 301 East 66th Street, right?
A.
I don't know specifically they stay at
Jean-Luc's apartment. But I know that the models
were staying in different apartments that belong
to Jeffrey Epstein.
Q.
And what are the names of the models
that were staying there, that you remember?
A.
Most of them. You know, at that time,
when I was there who -- all the little girls.
Q.
How do you spell that?
A.
I -- you know, that was in
2000-something. I don't recall all the names.
But there is a list that you can get it from the
office in New York.
Q.
A list --
A.
They have a list of models that they
were staying in those apartments.
Q.
If I were to request it from the office
in New York, what would I ask for?
A.
For the models' apartment list.
Chargeback for models apartments.
Q.
Chargeback?
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A.
Yeah, because Jeffrey Epstein never
charged Jean-Luc for rent but Jean-Luc was
charging rent to the girls. And in her statements
it shows 301, 66 Apartment A, or Apartment B. And
he was charging them, like, a thousand dollars a
month.
Q.
How do you know that?
A.
Because I was doing the statements.
Q.
You were actually the one doing the
statements?
A.
Not all the time. I was in New York
starting 2003.
Q.
Through what date? You were in New York
from 2003 to --
A.
2006.
Q.
And while you were in New York you were
working for MC Squared?
A.
Yes.
Q.
And what is the proof that you have seen
that Jeffrey Epstein was a partner or financial
supporter of MC Squared?
A.
I was the one who took the papers to
Mellon Bank.
Q.
That's in Miami?
A.
Yes. And Swetpaul (phonetic) -- I was
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talking at the time to Rich -- I believe his name
was Rich Gany. That was one of the other
assistants of Jeffrey Epstein.
Q.
Gany, G-A-N-Y?
A.
Yeah.
Q.
Do they call him Eric Gany?
A.
That is him name, yeah, Eric Gany.
That's his name. I recall some things, not all
the time. I recall that Mr. Epstein didn't want
to sign the papers, but Mellon Bank didn't want to
accept the Line of Credit if he didn't sign. So
we had to return the papers to New York so he
actually signed the documents.
Q•
And what was he actually signing, that
you remember? Signing over as a Line of Credit
or --
A.
As a line -- as the grantor of the Line
of Credit. Because the Line of Credit came from
J. P. Morgan directly, but he was the grantor. He
was the one who actually was responsible.
Q.
And how much was the Line of Credit?
A.
A million dollars, it was, at that time.
Q.
And did you ever keep track of whether
or not that line was extended or any additional
monies were given to MC Squared?
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A.
No, I don't know.
Q.
So in addition to his financial
guarantor on the Line of Credit of a million
dollars, what other involvement are you aware of
that Jeffrey Epstein had with MC Squared and/or
the apartments at 301 East 66th Street where the
models lived?
A.
They were planning on buying or
associating with a girl in -- in France for a --
for a company. They were planning to do a
company. And, actually, I gave the paper to -- to
Mr. Shawn Connolly, which is an actual paper that
came from the office from Jeffrey Epstein, that he
was giving instructions to Jean-Luc saying that he
wanted to have the same contracts as -- uh, what's
his name, of Donald Trump, and that he wanted to
have the same kind of benefits for the scouters.
So he was giving instructions to
Jean-Luc on what to do, what to -- there is a
woman in Paris, I don't recall her name,
(phonetic), I believe it was, and they were --
they were, the three of them, trying to do a new
company. But then everything was, like, on zero.
They never
they never did it together.
Q.
And do you know why?
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A.
No.
Q.
Would you know the lady's name in Paris
if I --
A.
If you give it to me, yeah. If you give
me the name, I can recall.
Q.
Okay. While I'm looking for that, how
many girls that were models were living in the
apartments at any given time at 301 East 66th
Street?
A.
That's -- that's not only one apartment.
There are a lot of apartments there. There is not
only one girl. There is not only one apartment.
I believe there were, like, two or three
apartments. And they were put in between four
girls per apartment, I believe.
Q.
How many apartments?
A.
I believe there were, like, two or
three.
Q.
And there is four girls per apartment?
A.
Yeah.
Q.
And you know that because you saw the
documentation at MC Squared that showed where
these girls were living?
A.
Yes.
Q•
Did you also have something to do with
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the visas that were prepared for the girls that
were working?
A.
Yes. I was providing the names to the
attorney. His name is Luis Font. He was doing
the visas here in Miami. There was another
Valenzuela was handling directly the visas in New
York. And only when she had problems, she hired
another attorney. I don't know the name of the
attorney in New York. But Luis Font is the --
was, at that time, the attorney handling the visas
for Miami.
Q.
Do you remember doing the visa for
A.
No, that was done in New York by III
Valenzuela.
Q.
And
visa, that you specifically
remember being done, right?
A.
Yeah, I remember that. Because at one
point, I believe, one of the renovations of her
visa, something happened. And Mr. Epstein called
the office while I was there and was really upset.
And he spoke with Jean-Luc and they -- they were
really nasty with III and, you know, it wasn't
if -- it wasn't
fault. It was their fault
because they gave the wrong information. But, you
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know, she was only an employee and that's it.
Q.
How did
come into the
country?
A.
By a model's visa, I believe.
Q.
And was she brought in specifically by
Jeffrey Epstein or Jean-Luc or do you remember?
A.
Mr. Epstein was paying for the visas.
But, you know, all the visas were done through --
through
or MC Squared. I believe she came
with
visa first, then everything
transferred to MC Square. And I believe those
visas were paid directly by Mr. Epstein.
Q.
How old was
when she
first came?
A.
I don't know. I wasn't in New York at
that time. Because I know she came prior to me
getting involved in New York.
Q.
And you were involved in New York in
2003?
A.
Yes.
Q.
So she came in some time before that?
A.
I believe so.
Q.
But even back in 2003, she still -- I
don't know how old she is now. She's probably 24
or 25, right; do you know?
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A.
No.
Q.
Have you ever met her?
A.
No.
Q.
Have you ever met
(phonetic)?
A.
No.
Q.
You have only met Jeffrey Epstein once
in person. How many times have you talked to him
on the phone?
A.
Maybe once.
Q.
At some point in time you drove several
girls or a number of girls over to Jeffrey
Epstein's house; correct?
A.
Not me. Jean-Luc directly took them. I
was making the arrangements to get a limousine or
a car. And Jean-Luc himself was driving the girls
to his house because he was having a party and
there were supposed to be girls.
Q.
Which girls did he drive over there?
A.
One time I know he went with
with
uh, what's her name? Four girls from
Brazil, from the same agency.
is one of
them because I remember her name. The other
ones -- maybe if you --
S2•
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A.
No.
Q.
A.
No.
Q.
Do you know those two girls?
A.
Yes.
Q.
And were those girls somehow involved
with Jean-Luc or the modeling agency?
A.
Yes.
Q.
They were both MC Squared models?
A.
Yes.
Q.
And at the time, when they began, how
old were they; do you remember?
A.
I believe
was, like, 14, 15. And
was 13, 14, when she came.
Q.
Okay. And do you know where they are
now, either one of them?
A.
I know
is in New York.
Q.
When is the last time you talked to her?
A.
In 2006.
Q.
How do you know she is in New York?
A.
Because I saw her pictures whenever. I
believe she's in New York. I don't know if she
really is in New York but I believe.
Q•
A.
, the last time I saw her was in
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2006, too. And, specifically, I don't know where
she is. But if she's in the United States, I
believe she's in New York. If not, she is in
Brazil or in Paris.
Q.
All right. Do you know this person in
Brazil,
A.
No.
Q.
Here is a document that we obtained
related to information from Jeffrey Epstein's
computer system. It says Massage Paris. It's in
a square there and it continues to the next page.
Tell me if you recognize any of those names.
A.
No.
is one of the girls
that went with
now that I'm seeing kind of
names. Lila is one of the other ones. If this is
Lelita or
something like that, it's a
black girl that I believe she was -- she was not
underage but she was going out with one of
Jeffrey's best friends.
Q.
Who is that?
A.
I believe --
Q.
Who is Jeffrey's best friend that she
was going out with?
A.
I don't know. I don't know.
something like that, is her name.
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Q.
All right. What information do you have
about Jean-Luc being involved with underage girls
at any point in time? And by that I mean being
involved sexually with underage girls.
A.
One day he told me that he wishes he can
sleep with one of those girls that was underage.
And I told him that's a minor, whatever. And
then -- hold on, that's my son.
(Telephone interruption.)
A.
He had a problem, you know. I cannot
say I saw them, look, because I would be lying.
And I'm not going to say any lie. But the only
thing that I can tell you that what I saw about
Jean-Luc is that Jean-Luc is a drug addict, a
cocaine addict.
Q.
At some point in time you actually saw
evidence of that, right?
A.
Yes.
Q.
I mean, him using cocaine that somebody
does every day?
A.
Yeah. He's an addict. He's used to
drugs, as well as, you know -- I know Mr. Epstein
doesn't take any alcohol, drugs. I know that. I
heard that.
Q.
How do you know?
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A.
I heard that. I heard that. I don't
know, because I never met -- I never -- I was
never, like, around him or nothing like that. I'm
just telling you what I heard. But regarding
Jean-Luc, I know -- I know he has that kind of
problem, no?
Q.
And as long as you knew Jean-Luc, he
always had a cocaine problem?
A.
Yes.
Q.
What about Jeff Fuller?
A.
I know he had a cocaine problem, too.
He was one time on the Internet, you know, like, a
report on that.
Q.
And is Jeff Fuller somebody else who you
also knew to have been associated sexually with
underage girls?
A.
Jeff, I -- you know, I don't think Jeff.
I always thought Jeff was gay. For me, he's gay.
You know, that's the impression that I have. But
I don't think so.
Q.
Did you find out that Jeffrey Epstein
and/or Jean-Luc Brunel were involved in these
underage girls that were staying in these
apartments at 301 East 66th Street?
A.
I really don't know that. You know, I
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cannot tell you. I know there were girls staying
there. I never knew if they were going there or
not.
Q.
You mean, you knew that the girls were
staying there; 13, 14, 15?
A.
Some of the girls were underage, yeah.
Q.
As well as 13, 14 or so?
A.
Thirteen or 14, yeah.
Q.
Did you ever ask any of the girls if
they were sexually involved with Jean-Luc and/or
Jeffrey Epstein?
A.
No. One time there was a problem with
And she was -- I believe she was
14 years old. And she tried to go -- or they took
her to a discotheque in Miami Beach. And when I
went to work the day after, they told me that the
police was asking. So since she was doing
whatever she wanted, you know, I brought her to my
house and I said, you're not going out at night;
you're only 13, 14, and that's my responsibility.
Q.
Do you know Sergio Cordero?
A.
Yes.
Q.
And do you know what Sergio's role was
in getting girls or something for Jeffrey Epstein?
A.
Yeah. That -- that is something that
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Sergio, you know, comment with me. And he said
that when Jeffrey Epstein went to Ecuador,
Jean-Luc told me that he has to bring girls and
this and that, because Jeffrey was coming to
Ecuador. So they did such a big thing.
Q•
Right. But in terms of bringing girls,
specifically girls, that were very young?
A.
Yeah, but there was girls from Ecuador.
There is nothing you can do there. It's South
America.
Q.
I understand that. I'm not saying
whether it was legal or illegal. I'm just asking
you, the direction was that Jean-Luc told
Sergio
A.
Not to bring girls. Never said --
never -- Sergio knew that they like young girls.
Q.
By young, what are we talking about?
A.
Eighteen, 19. Sergio -- you know, I
know Sergio. And more than anything, like, Sergio
is a father. And I don't think he will put his
hands on a ten, 11, 12, 13-year-old girl. You
know what I mean?
Q.
I'm not asking about him. Do you know
of Jeffrey Epstein being involved with underage
girls?
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A.
I heard that, yeah.
Q.
You heard that through whom? I don't
mean just the newspapers and things like that.
mean --
A.
No. Through -- through the office.
Through Jean-Luc. Through -- there were
conversations of Jean-Luc saying that, you know.
Q.
Saying what?
A.
That Jeffrey likes underage girls. And
never directly but, you know, his conversations
were like that.
Q.
Okay. But, specifically, I just want to
know what evidence that we have, what real
conversations that you heard, about Jeffrey
Epstein liking underage girls.
A.
I'm telling you Jean-Luc saying it from
his mouth.
Q.
Okay. And, specifically, he says
Jeffrey Epstein likes underage girls or he likes
12-year-olds or likes what?
A.
No, he likes young girls. When they
were talking in the office, there were a lot of
people. So they were not stupid. They were
knowing how to talk. Because they were making,
like, a big thing of, oh, look, he's going out
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with Fulanita (phonetic), and we knew Fulanita was
only 18 years old. She is a young girl. So
that's the kind of girl he likes. You know what I
mean?
Q•
But there is nothing illegal going out
with an 18-year-old girl. And that's what I'm
asking.
A.
No.
Q•
What information do we have that Jeffrey
Epstein was involved with underage girls? I mean,
I have a lot of information of my own. But I'm
asking what information do you know.
A.
The only thing I heard in the office,
that Jean-Luc say it, that they like -- when they
say, oh, I wish I could sleep with this girl or
the fact that he was taking 15, 16-year-old girls
to his house.
Q.
Who?
A.
I know that because I saw him.
Q.
Jean-Luc was taking 15-year-old girls to
his own place?
A.
No, to Jeffrey's house.
Q.
A.
Q•
To Jeffrey's house?
Yes.
And what 15-year-old girls was he taking
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to Jeffrey's house?
A.
At the time I'm telling you it was Lila,
I don't know remember the other two
girls. There is two Brazilian girls. I gave it
to you before, the names. I don't remember right
now.
Q.
Do you know
A.
No.
Q.
Do you know Khalid Mohammed?
A.
Yes.
Q.
What did he do?
A.
He was a scouter and a booker.
Q.
Scouter; what does that mean?
A.
Person looking for models.
Q.
And how legitimate was
A.
Khalid Salaam.
Q.
Salaam?
A.
Yeah.
Q.
Right. Where was he bringing models in
from or looking for models? Outside the country
or --
A.
Inside the country. Very -- not often
from outside the country, no, no. From inside.
Q.
Did you ever hear of any of the parties
that took place on Jeffrey Epstein's island?
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A.
In --
Q.
Little St. James?
A.
One New Year's, I believe -- that was,
like, 2004, 2005, that New Year's -- they were
having a party there.
Q.
Who was having a party there?
A.
Mr. Epstein.
Q.
And who was at the party that you know?
A.
I know Jean-Luc was there. But then --
specifically, I don't know if Jean-Luc stay there,
because what I do recall is that, during those
days, there was, like, December 30 or 29,
something like that, Jean-Luc call me from Puerto
Rico that he was doing the scouting and he --
actually, he was the one who told me that he had
to go to Jeffrey's island because they were having
the party there for New Year's.
Q.
What other girls do you know of that
were at that party?
A.
I don't know.
Q•
Do you know of any of the other people
that were at that party?
A.
No.
Q.
Just Jean-Luc and Epstein?
A.
Yes.
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Q.
The last time that we talked, I have
just the investigative report, which basically was
just typed up from the things that you said. It
was written that Ms. Vasquez advised that she,
herself, submitted the documents to renew
foreign visa on at least two occasions.
A.
No, not me. It was
Valenzeula.
I never did her visa. That visa was done by
in New York.
Q.
When is the first time that you learned
that
was involved with Jeffrey
Epstein?
A.
I believe in 2007. After I was out of
the company.
Q.
You didn't know, when you were in the
company, that they were involved?
A.
No.
Q.
All right. At some point in time, did
you get in trouble, criminal trouble, related to
MC Squared?
Q.
They accuse me in 2006.
Who accused you?
A.
Jeff.
Q.
Jeff Fuller?
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Q.
What did he accuse you of?
A.
Of stealing money. And I had a letter
from Jean-Luc authorizing me to get the money that
I had, you know.
Q.
And did you ultimately have to plead to
criminal charges because of that?
A.
That was my -- what my attorney told me.
Q.
Yeah?
A.
Yeah.
Q.
So now you're on probation or something?
A.
Yes.
Q.
How long does the probation last?
A.
They did it for 20 years. So I'm just
trying to reduce that.
Q.
Twenty-year probation?
A.
Yeah.
Q.
And other than Jeff Fuller, who else
was -- who else was making these accusations?
A.
Only Jeff.
Q.
How about Jean-Luc?
A.
I never -- my attorney told me that
Jean-Luc was never interviewed, nothing.
Q.
Jeffrey Epstein?
A.
No.
Q.
Have you talked to Jean-Luc about the
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whole situation?
A.
I spoke with Jean-Luc on two or three
times. I spoke with Jean-Luc, like, two or three
times during -- prior to the middle of the
process, I did -- and I still have an e-mail that
he send me because he wanted to talk to me, I
wanted to talk to him. And I never made the time
because Jeff Fuller didn't allow him to talk to
me. So we never got to get together to talk.
Q•
And they prosecuted the case in Federal
Court here in Miami?
A.
Yes.
Q•
And your entire sentence was probation;
there was no prison or house arrest?
A.
House arrest one year. That, it was
done already. And then probation.
Q•
The last time, I have a lot of other
notes about some of the models that were being
brought in and signing visas, as if they were
going to work here, but really they were living in
the apartment and didn't really do any modeling
work.
A.
Yeah, that is true. That is true. I
told you that. Many, many girls were coming here.
Many girls were coming here first without a visa,
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without a working visa. Most of the girls, they
were coming in to the States as tourists. They
were working -- whenever they work, they were
collecting 30 percent from their income when they
were not even legal. They didn't even have a
Social Security or nothing but they never pay it.
Neither to the government, neither to the girls,
you know. And within the time, I believe Jean-Luc
start getting pressure from Mr. Epstein that he
didn't want to get in trouble and he put some
pressure on Jean-Luc. So he wanted all the girls
to have a visa. So they start working on the
visas of the girls.
Q.
Okay.
A.
And they were making, like, contracts or
things like that. Because, prior to that, they
didn't have it. Prior to that, when Jean-Luc
prior to Jean-Luc getting the money from
Mr. Epstein, Jean-Luc was doing whatever he
wanted.
Q.
Okay.
A.
And later, you know, Mr. Epstein put the
money that he had to start taking, you know, all
the invoices from Mr. Epstein.
Q•
Does Jeffrey Epstein know that Jean-Luc
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is a coke addict?
A.
I don't know. I don't even know that
Mr. Epstein knows that Jean-Luc lied to him all
the time. Because when he -- when I gave the Line
of Credit to Jean-Luc, Jean-Luc presented false
statements to him. You know, Mr. Epstein wanted
to see that the company was a profitable company
and we had to hide all those numbers. And we had
to give him, like, positive numbers so he can see
that the company was making money but in belief
always was in red.
Q.
What do you mean by that? Jeffrey
Epstein said, hey, I'm going to give you money as
long as the company is positive?
A.
Yeah. Mr. Epstein wanted to see -- I
believe -- I believe, since he's a very successful
person moneywise, he was not stupid to put his
money, even though he knew he was able to get
girls or whatever, you know, if that was the case.
But deep inside he wanted to see if these people
really -- if this company was profitable for him
to put a million dollars.
So maybe Eric Gany, at the time, was one
of his advisors. And they wanted to see the
profit and loss statements and, you know, the
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balance book or whatever.
I told you the name of the accountant
that you could go and took all those papers, you
know, make a subpoena or whatever, of Richard
Fernandez, that he could give you all the
information, 1998, '99, 2000, after 2005, that he
did everything and you could see the company was
always in red, always.
Q.
So the company wasn't profitable but
Jean-Luc falsified documents to show to Jeffrey
Epstein?
A.
Yes.
Q.
And have you seen the real documents and
the falsified documents?
A.
Yes.
Q.
So you know that they were falsified?
A.
Yes.
Q.
Is it your understanding that Jeffrey
Epstein is still involved, from a financial
aspect, in MC Squared?
A.
I believe so. Because, as far as I
know, the Line of Credit wasn't paid. The million
dollars wasn't paid.
Q.
And Jean-Luc and Jeffrey Epstein are
still friends?
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A.
Yes. Jean-Luc is still living in
Jeffrey Epstein's apartment in New York.
Q.
How do you know that?
A.
Well, because -- because I know.
Q.
From
A.
Yes.
Q.
Is
still working for MC Squared?
A.
No.
Q.
Do you know who is working for MC
Squared?
A.
It was working until not too long ago a
very --
goddaughter,
, she was
working there.
Q.
How do you spell it?
A.
Q.
Okay. Anybody else?
A.
In Europe?
Q.
Yes, or here.
A.
No, that was related to
Q•
No,
Who works in the MC Squared office here?
A.
Here, I knew other things, because
Amanda Grant and -- I gave you her name more than
one time. Amanda was working with them until
2008. And she got a lot of information. And she
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wanted -- you know, she call -- I arrange she call
Immigration, because they screw her. And,
actually, they made her leave the company because
she has -- she is a single mother, four kids. And
they were giving her a lot of bad -- bad time.
(Telephone interruption.)
Q.
How do you spell her name, Amanda Grand,
G-R-A-N-D?
A.
N-T. Amanda Grant.
Q.
And do you know her address, phone
number; something like that?
A.
I have -- you can get it in Facebook.
She's in Facebook. Amanda Grant.
Q.
Do you have it?
A.
Not in this phone. My other phone broke
so I don't. I can get it for you, if you want.
Q.
Yeah, I would appreciate it.
A.
Yeah.
Amanda had also the information of
monies, as I told you before, that took monies
that they were transferred to the British Virgin
Islands.
Q.
Monies transferred to the British Virgin
Islands?
A.
Yes.
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Q.
From what account to what?
A.
Jean-Luc opened an account there because
Jeffrey told him that it was better to open an
account there. So there was money -- like, for
example, if the monies were going to Manuel Cruz
to do a shoot or something, Jean-Luc was
negotiating with the girls and say, okay, if you
go to do the sunny photos, I give you $2,000 cash,
no reports, whatever.
So Jean-Luc had -- as billing that
company from another company, or from the British
Virgin Islands. So he was neither paying taxes
here and maybe he was making $20,000 on that
shooting and he was giving the girl only $2,000
and that money never came to be reported here.
Q.
Okay. Other than you saying that you
know that a 15-year-old or so went to Jean-Luc's
house with him, how else do we know that Jean-Luc
and/or Jeffrey Epstein, I'm more concerned with
Jeffrey Epstein, were involved sexually with
underage girls?
A.
How do I know? I -- I -- I cannot tell
you that I saw -- that I was there because that's
not true. I never saw anything.
Q•
Right. But sometimes you just know?
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A.
Yeah, sometimes -- and that's -- that's
what I can tell you. I know because -- I can tell
you about Jean-Luc, that I know because I met him
for ten years. Okay? I can put my hands on fire
and I can tell you that he did it. About Jean-Luc
I can say it. I don't know about Mr. Epstein
because I was never -- I met him once in my life.
I saw him once in my life. And after that, when I
saw him, was in the newspapers; that's it.
Q.
And, otherwise, you just heard that
Jeffrey Epstein likes underage girls?
A.
Underage girls, yeah.
Q.
And there was a time where Sergio --
well, I've talked to Sergio, so I'll talk to him
about whatever the Ecuador trip was.
A.
Yes.
Q.
All right. Do you know of this company,
COUQ --
A.
No.
Q•
-- Foundation. All right. Do you know
of somebody by the name of
A.
No.
Q.
Somebody who provided Jeffrey Epstein
girls?
A.
No.
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Q.
How about
A.
No.
Q.
Never heard that name?
A.
No.
Q•
A.
I believe I heard that name. But I --
Q.
She works up in New York and I believe
she works for Jeffrey Epstein in some capacity.
Do you know what that is?
A.
I believe so. No.
Q.
Okay.
A.
The person who can tell you that is III.
Because III was very involved with Jeffrey
Epstein's office.
Q.
What is
number again?
A.
Q.
Do you know Jojo Fontanella?
A.
No.
Q.
No? Other than Jean-Luc, what other
people that are friends with Jean-Luc share this
interest in underage girls, that you know of?
A.
No.
Q•
I mean, who are his friends? Who are
the guys he hangs out with?
A.
Jeff. When he was in Miami, Jeff,
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Corrado.
Q.
Who is Corrado?
A.
A friend of Jean-Luc. An Italian guy.
They were always like that, Corrado and Luc. I
met Jean-Luc's friends in Ecuador, like people
that had to be -- people that they were involved
with modeling agencies in Europe, in South
America, but very different people, very different
people. I met some people from France. Pero,
really, even if they were guys or whatever,
gentlemen. You know, like, very proper people.
Like, from Brazil, too. And the womans, you know.
Q.
How about Simon Parra; you know who that
is?
A.
Simon Parra, yeah.
Q.
How do you know him?
A.
I met him through Jean-Luc.
Q.
And what's his story?
A.
Mr. Parra was a very good friend of the
office. I cannot say of Jean-Luc because he was
only a friend of him. He was a very good friend
of the office, because Mr. Parra is a gentleman.
He was lending money to the office. Whenever I
requested, he always gave it to me for the office.
You know, that I signed -- I had to sign papers
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for him or whatever, to -- to do the payrolls or
whatever. But Mr. Parra is a guy that he likes to
be surrounded by girls. But not underage girls.
Q.
Okay. What was Jeffrey Epstein getting
out of MC Squared?
A.
The only thing that I can think he was
getting was the girls. Nothing else. Because he
has all the money.
Q.
And the company wasn't making money
anyway?
A.
No.
Q.
And you know the company wasn't making
money?
A.
It wasn't at all. At all. So the only
thing that he was -- I believe that he wanted to
get involved was because of the girls, that's it.
Pero, he wanted to do it legally, like, girls
coming here, even if they were underage or
whatever, with visas.
Q.
Because the modeling industry is one of
those industries where there is a lot of girls
underage coming in the country, right?
A.
Yes.
Q•
girls?
That's pretty easy access to underage
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A.
Yes.
Q.
And they come in the country and they
don't have their parents?
A.
Yes.
Q.
So they don't really have any parental
supervision while they're here?
A.
Not at all.
Q.
So the modeling industry is one that
some guys use that to get underage girls and
that's happened for a long time, really, right?
A.
Yes.
Q.
So is that what Jean-Luc Brunel still
does?
A.
Yes.
Q.
Still uses it to get underage girls to
sleep with, really, right?
A.
Yes.
Q.
And Jeffrey Epstein, too?
A.
I cannot tell you that because I don't
know. I know if there is -- there is kind of a
relationship, I believe they will or he will. You
know, he still does it. But I don't know. I
cannot tell you because I was never -- I was
never -- what I can say that I know, because I was
with that person for the longest, was with
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Jean-Luc. The same thing that I can tell you,
that even if he has a daughter, whatever, I put my
hands on fire that Jeff Fuller is gay.
Q.
Okay. And Jean-Luc, you saw him use
cocaine at work?
A.
Not in the office. But sometimes he was
coming to the office, like, with blood coming from
the nose and white things here, that he had to go,
oh, you go and clean yourself or whatever, you
know.
Q.
Would he talk about his cocaine
addiction?
A.
Not directly, but it was a box properly,
everyone knew about that. And he was the one
the kind of person who didn't feel ashamed to
tell. For example, Sergio was there and I was
here and he was there and he was, like, Sergio, go
and get me the best one, you know. And Sergio was
going and getting it for him.
Q.
So he didn't really hide the fact that
he used cocaine?
A.
No. No. But not in the office, not in
front of the bookers.
Q.
Where is the office in New York?
A.
Six West 14th Street.
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Q•
now?
And do you know what Khalid is doing
A.
No.
Q.
Is he in Miami?
A.
Yes, he's in Miami.
Q.
Do you know his number?
A.
No, I don't know his number.
Q.
How about Mike Sanka?
A.
Michael Sanka, he's in California.
Q.
What did he do?
A.
He represents -- he represents artists,
players. He is, like, a manager.
Q.
Did he have any role in procuring
underage girls for anybody?
A.
Never. No. Not at all.
Q.
How about Arnaud Brunel?
A.
He's Jean-Luc's brother.
Q.
Is he here in Miami?
A.
No.
Q.
Where is he?
A.
France.
Q.
Has he ever been here in Miami?
A.
Yes.
Q.
When is the last time you talked to him?
Been a while?
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A.
2006. No, 2003.
Q•
Okay. Is he close with Jean-Luc?
A.
No. Well, he's his brother, you know.
Q.
Yeah.
A.
There is a blood relation there. But I
can tell you it's, like, oil and water, two
different persons. Two different heads. Two
different mentalities.
Q.
Who are the people --
A.
A gentleman and a beast. Mr. Arnaud
Brunel is a gentleman, a very correct person, very
transparent. The other is the opposite.
Q.
Do you know this guy, Etienne?
A.
Etienne Rau. He was another partner of
Jean-Luc, in
. Another gentleman, another
real good person. Actually, Jean-Luc screw him
and he took him out from
.
He closed
here in Miami, without Mr. Etienne's
knowledge.
Q.
And if we talk to Etienne, he would not
have nice things to say about Jean-Luc?
A.
No. Not at all.
Q.
What about --
A.
Ruth.
Q.
Who is that?
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A.
Ruth, the other lady in Paris. It's the
same thing. She will tell you everything.
Jean-Luc came from Paris --
Q.
How do you spell her name?
A.
I don't know her name. Her last name I
don't know. Her name is Ruth. R-U-T-H. Like, he
came from Paris. Because if he stay in Paris, he
had to pay taxes and this and that. Everything
that he was avoiding.
Q.
Who, Jean-Luc?
A.
Jean-Luc.
Q.
Do you know how he and Jeffrey Epstein
became friends?
A.
No.
Q.
Or why they became friends?
A.
No.
Q.
I mean, other than underage girls, what
else do those two have in common?
A.
That's the only thing, I believe. And
it's very -- you know, like, I saw Mr. Epstein
once in a gym, in a church, very simple. And you
see Jean-Luc on the same place and you see
Jean-Luc with a -- Prada pants and with a Gucci
T-shirt and with Dolce Cabana sunglasses. It's
like two different characters.
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Q.
And how many girls, at any one time,
would MC Squared have under them?
A.
A lot. Like, over 200, 300.
Q.
Other than the one time where four girls
were taken to Jeffrey Epstein's house -- and all
four of those girls were underage at the time,
right?
A.
Yes.
Q.
They were 14 or 15 at the time?
A.
Yeah, 15, 16, 14; something like that.
Q.
Other than that time, what other
occasion -- jog your memory, think this through --
have you known of Jeffrey Epstein to be in the
same vicinity as any of the models? Was there
ever a time that Jean-Luc says, hey, Jeffrey
Epstein is coming up to New York this weekend,
we're going to hang out at the apartment or
Jeffrey Epstein is this?
A.
No. Never. Jean-Luc never mentioned
his name until 2003, when, actually, Mr. Epstein
got involved. To me, you know, to me. Prior to
that, one more time, you can talk to III. She
knew Jeffrey Epstein prior -- prior to me.
Q.
Before you did?
A.
Yes.
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Q•
have?
And she has seen him more often than you
A.
Of course, because she was in New York
all the time. She live in New York and I never
live there. I was, like, commuting one week in
New York, two weeks in Miami. One week in New
York, two weeks in Miami.
Q.
Are you leaving to go to Colombia soon?
A.
To Peru.
Q.
To Peru?
A.
Yeah.
Q.
When?
A.
The 24th.
Q.
And do you know when you're going to be
back?
A.
The 28th.
Q.
All right. Like I said, I would hope
and think that this whole thing -- that your
involvement is completely done. However, there is
one case that Jeffrey Epstein has not settled
right now that could go to trial. If it went to
trial, then we could be called at trial. But it's
highly unlikely that is going to happen. I'm just
letting you know there is a possibility.
do you know who that is?
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A.
No.
Q.
A.
No.
Q.
A.
No.
Q•
A.
No.
Q.
-
A.
No.
Q.
A.
I know -- I didn't mention
her because I didn't remember her name. Now you
say it,
was a girl who was working for
She was not underage but she was a young
girl. She was working for
. She was
studying and she was living at Jeffrey Epstein's
apartment. She was living at his place.
Q.
And what was her involvement with
Jean-Luc and/or Jeffrey Epstein?
A.
She was working at
lot?
Q•
Okay. As a model?
A.
No. She was a -- an employee.
Q•
She traveled on his airplane with him a
A.
Yeah, because she's a personal friend of
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Jeffrey. She was living in his place.
Q.
Anything else about him that --
A.
No.
Q.
Or about her?
A.
No.
Q.
A.
No.
Q.
Any other people that you know that were
living in that apartment at any time?
A.
No.
Q.
Other than the people that you named
already, which are now
A.
I don't think
lived there.
was living in one of the models' apartment that we
rent. Because besides those two apartments, we
rent apartments in New York for the girls.
Q.
Who decides whether the girls live in --
A.
Jean-Luc.
Q.
Jean-Luc decides whether the girls live
at 301 that's owned by Jeffrey Epstein or the
other apartments that are rented by MC Squared?
A.
Yeah.
Q.
And how does he make that determination?
A.
He's the owner.
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Q.
Oh, but, I mean, what are the
qualifications? I mean, if he likes the girl or
they're underage or they're --
A.
No, if there were, like, good girls,
girls that they could make money, they were living
in an expensive place. If they were, like,
regular girls, they were living in shitty places.
Q.
Okay. But which one is Jeffrey
Epstein's place?
A.
An expensive place.
Q.
Okay. So the better models were living
there?
A.
Yes.
Q.
do you know who that
is?
A.
No.
Q.
Did you ever meet with
A.
No.
Q.
Did you know that she was friends with
Jeffrey Epstein?
A.
No.
Q.
Did you ever meet
A.
That's the woman that was involved with
Mr. Epstein, no?
Q.
No.
is the owner of
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Victoria's Secret?
A.
No. No. He was a writer.
Q.
No. He's the owner of Victoria's
Secret, The Limited, Abercrombie.
A.
No. No.
Q.
Did you ever hear anything about Jeffrey
Epstein's relationships, who he was with: Male,
female, a person's name?
A.
I knew, because III told me that he had
a relationship with a woman that her father was
very wealthy and that's how he started his own
money. And if you tell me the name, maybe I can
remember. But I don't --
Q.
Ghislaine Maxwell?
A.
Yes.
Q.
And her father was Robert Maxwell?
A.
Yes.
Q.
Other than that relationship, are you
aware of any other relationships of Jeffrey
Epstein?
A.
No.
Q.
How many times are you aware of Jean-Luc
bringing underage girls to Jeffrey Epstein's home
in Palm Beach?
A.
While I was there, when I was working
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with them, maybe -- maybe two, three times a year.
The last year; you know, 2003, 2004, 2005.
Q.
And how would you know --
A.
Not prior to that.
Q.
How would you know that Jean-Luc was
taking underage girls to Jeffrey Epstein's house
during those years?
A.
Because he was saying in the office:
There is a party at Jeffrey's house; I'm taking
the girls. And the girls, that they were in town,
they were, like, underage girls.
Q.
We are still talking about 14, 15?
A.
Sixteen, yeah.
Q.
Sixteen, at the oldest?
A.
Yes. And they were going, the other
girls, too, but he -- he personally was taking the
little ones. Because the other ones, they could
go in their own cars or whatever, you know, with
their boyfriends.
Q.
Did you ever say anything to him about
taking underage girls to Jeffrey Epstein's house?
A.
You know, as a mother I always told him
that they were underage girls. And he was saying,
oh, that I'm the father.
Q•
But you knew what was going on?
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A.
Not really. Not really. Not really
that -- because I would never think that they were
going to a party. And I didn't know Mr. Epstein
in that scenario, you know. I know Jean-Luc was
crazy or is crazy, but not stupid to be with those
particular girls, because these girls were coming
from a very good friend of him in Brazil.
Q.
Who is that?
A.
And he didn't
I don't remember her
name. The mother agent of these four girls. I
gave it to you before. I don't remember her name.
It's a black woman.
Q.
It's not
A.
No. What's her name?
Q.
Because I have that part of the report
right here, stating that Brunel had a connection
with a young Brazilian woman but I don't have a
name for that person.
A.
No. He was having a connection with a
woman in Brazil that she was giving him
prostitutes when he needed it.
Q.
The connection woman in Brazil was
giving Jean-Luc prostitutes?
A.
Real prostitutes when he needed it.
Q.
How old were these prostitutes?
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A.
I don't know. I don't know because I
was never in Brazil with him or nothing like that.
Q.
In Brazil?
A.
In Brazil. That was in Brazil.
Q.
Was Jeffrey Epstein involved in these
A.
Jeffrey Epstein was going to Brazil
because he has one or two clients that they're
from there. So they were going, they were meeting
there and everything like that.
Q.
So you know of at least occasions where
Jeffrey Epstein and Jean-Luc were in Brazil --
A.
Yes.
Q.
-- and there was a particular person
that would provide prostitutes for them?
A.
Yeah, because one time I know because
Jean-Luc say it to me openly.
Q.
What did he say?
A.
That that woman was giving him, not
models; they were prostitutes.
Q.
In my notes it says underage
prostitutes. Is that something that --
A.
Yeah, maybe. They were underage girls.
Like, 16, 17, 18.
Q.
Ms. Vasquez stated, tell me if you agree
with this, that Brunel would have her prepare a
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list on a weekly basis that covered changing out
or replacing the girls staying in Epstein's
apartment and providing them with living expenses,
as well. And then it goes on, saying that he
charged them rent?
A.
Yeah, yeah. He was the one who said who
stays in what apartment and -- actually, what he
said is, like, A, B, C, stays in Jeffrey's
apartment. So that was the order. That's it. So
the rest, III was supposed to put in whatever she
wanted.
Q.
The notes indicate that you -- you were
talking about
being a Russian,
14 years old, that lived in Epstein's apartment?
A.
No. I never said that.
Q.
You weren't there then?
A.
No. I never said that. So whoever
wrote that, I was never --
Q.
This is written off typing notes because
obviously we didn't have a reporter to get it
down. So that's why I wanted to get her here so
that we know exactly what your story is. It would
make it easier.
A.
I heard of that girl. And I remember
clearly that it was a problem with her visa. And
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that's why she -- I remember there was a -- end of
the year and I was with III in New York and she
was, like, really upset because they were, like,
mistreating her because of that; the fact that
they were blaming her for the papers, doing it
incorrectly. And then III told me, you know, that
girl never work, she was never a model. She was
living in his place but she disappear. So she
actually never even worked as a model.
Q.
A.
Yeah.
Q.
And that's just something ■
knows
because ■
was there?
A.
Yes.
Q•
now?
All right. Do you know where ■
works
A.
At Hope Community.
Q.
What's that?
A.
It's a government organization in New
York.
Q.
Has she spoken with the F.B.I.?
A.
I don't know.
Q.
Have you been contacted by the F.B.I. or
any government agency related to Jeffrey Epstein?
A.
F.3.I. ?
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Q.
The F.B.I.
A.
Yes.
Q.
When was that?
A.
In 2008.
Q.
2008?
A.
Yes.
Q.
And where did you meet with them?
A.
In my office at the Four Ambassadors.
Q.
At the Four Ambassadors. That's where
Sergio is, too, right?
A.
Yeah.
Q.
So do you still see Sergio?
A.
I spoke with him sometimes; once in a
while.
Q.
Did Sergio have to speak with the
F.B.Z., as well?
A.
I don't know.
Q.
Do you know of anybody else that spoke
with the F.B.I. about Jeffrey Epstein?
A.
I don't know. I don't think Eva spoke
with him -- with them. I don't know.
Q•
And what did you tell the F.B.I.?
A.
I told them everything that I -- the
same thing that I knew. At that time I even had
maybe more information. I gave everything from
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Amanda and everything like that. But the lady --
Q.
?
A.
Yeah,
.
That was her name. She
was, like -- I told her, you have to go -- go to
Immigration. I say, go visit over there. And
when I call her once she told me: You know what?
I need -- I need fact. I need proof, I need
girls.
I say, well, I'm giving you the tools
that I have. There is nothing else that I can
I cannot create something because I don't create a
story. I tell you what it is. This is the fact.
You go and you can use this to also do something
else. But if your point is, you know, minor
accusations, like underage girls being with him in
the bed, I'm not going to say anything because I
don't know. I wasn't there. I don't know. What
I heard, my ears heard, you heard, she heard,
whatever.
Q.
From Jean-Luc is the only person you
heard it?
A.
Yeah.
Q.
Or
?
A.
Yes. That's it.
Q.
Who probably heard it from Jean-Luc?
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A.
And who probably heard it from Jeffrey's
office. I don't know.
Q.
Okay. But in terms of things that
happened at Jeffrey Epstein's house or homes
around the country, you don't know?
A.
Nothing. We have never been involved
with that gentleman or his own things. Never.
Q.
It was only a relationship with
Jean-Luc?
A.
For the office. That started 2003.
That's when he -- that's when he actually gets
involved.
MR. EDWARDS: All right. I believe
I'm done. Hold on a second.
BY MR. EDWARDS:
Q.
When Jeffrey Epstein was in jail, did
you know of Jean-Luc going to see him regularly?
A.
No.
Q.
Did you even know that he went to jail?
A.
Yeah.
Q.
I mean, at some point in time, but while
he was in jail, did you know for any other reason
other than newspapers that he was there?
A.
No.
Q.
Have you ever heard of this guy, Joe
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Pagano (phonetic)?
A.
No.
Q.
Larry Vasasky (phonetic), do you know
the pilot?
A.
No. With his personal things, we
never
as far as I know, me personally, never.
Q.
Yeah, no, I'm only asking you about
people who were on flights with Jeffrey Epstein
and Jean-Luc. So that's why I was thinking that
maybe Jean-Luc would say who was on that flight.
A.
No, because I know one time I know he
came in his plane and he forgot Gucci pants in his
airplane. So we had to go to the airport to pick
up the pants. But I had to wait outside and
somebody went inside to pick up the pants.
Q.
(phonetic); do you
know who that is?
A.
No.
Q.
Was there a Colombian girl, 13 years
old, approximately, being protected by Jean-Luc?
A.
Colombian girl?
Q.
That's all the information that I have.
No?
A.
No.
Q.
Who else would process the visas for the
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underage girls?
A.
At that time, it was Evelyn Valenzuela
in New York. And whenever she was not able to do
it, she hired an attorney. I don't know the name
of the attorney in New York. And in Miami the
person who was doing everything for visas was Luis
Font.
Q.
Who are the people that -- that are --
you know most of Jean-Luc's friends. Who are the
people who dislike Jean-Luc? Who are the people
we should talk to about they know him, they're
familiar with him, but they're going to tell us --
A.
Talk to Khalid.
Q.
Khalid?
A.
Yeah, talk to Khalid. Talk to Amanda.
Q.
You don't know how to track Khalid down
right now?
A.
Amanda can give you the information of
Khalid.
Q.
Amanda Grant?
A.
Yes. And I'm going to give you a
letter
I'll send you an e-mail of Amanda's
telephone number. I go into my Facebook and I ask
her.
Q•
Okay.
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A.
And who else? Who else? Talk to Elit.
There is -- there is a lot of people in New York.
But you ask III. Ask III. She can give you the
names. I don't know the names exactly. I gave
Conchita a name. And I thought that this woman
was really upset with him. But when she call her,
it was, like, the girl was talking too much
flowers about him. So it's, you know --
Q.
So you never know?
A.
Yeah. You never know. That is true.
You never know. Five thousand dollars in Brazil
is a lot of money. You know, you can buy a house.
Q.
So you can also buy somebody to be
quiet?
A.
Money talks. That's what they doing all
the time.
Q.
Do you know of Epstein paying anybody
off during this whole litigation?
A.
If I know, I don't know. But I can say
that, yes, because if it wasn't Jeffrey Epstein,
if it would be Juan Perez, believe me, Juan Perez
would be put in jail forever and ever.
Q.
Who?
A.
I'm giving you a name.
Q.
Oh, right. Right.
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A.
Because he's Jeffrey Epstein and he has
all the money he has, he could shut up everybody.
But if it would have been Juan Perez in the same
situation, Juan Perez would be right now all his
life in jail.
Q•
But do you know of any people that
Jeffrey Epstein had paid during the civil
litigation
A.
I don't know.
Q.
-- to not talk or to go away?
A.
I don't know.
Q.
Or -- I mean, I'm sort of surprised that
we haven't heard more from the models who were in
New York, didn't make it as models and were only
up there in the apartments for Jeffrey Epstein or
Jean-Luc.
A.
Because not all the models, even if they
are underage, they agree to do whatever they want.
You know, like, in my case, I was -- when I was
with the girls and I was talking to the girls, I
always said, you know, like, you are going to do a
job. You're not being hired to do nothing else.
You work for nine to five. Even if you go to do a
three-day in San Francisco and the owner of this
company wants to ask you something, it's up to
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you. You're hired to do your job. After that, we
have no control.
You know, they were -- there were girls
that they were going to do jobs of 100,000,
$200,000. And they were coming, they're real
upset, that they never wanted to work again with
those people, even though they were paying.
Because they were, like, molesting. No way; I'm
here to work. That's it.
Q.
Who were those people?
A.
For example, there is a girl, a
Brazilian girl, what's her name?
She did a job in San Francisco. And
the guy wanted to --
Q•
Do you know her last name?
A.
No. No. I don't remember. And the guy
wanted to take her out in his yacht. And she
said, no, I'm going back to my hotel. I'm here to
do my shooting from nine to five and that's it.
And the guy didn't want to shoot her that next day
and he return her in a private plane. But we had
to find for her money because she had a three-day
shooting for $15,000 for each day or $20,000 each
day. And because she didn't want to go with him
in the boat, he didn't want to have her anymore.
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But my contract was for three days. That's not my
problem.
Q.
Who were some of the other people that
you found out later were trying to molest the
girls?
A.
No; I found out because I had a very
good relation with
called to
complain and she want all her money. If not, we
are suing them. So I had to call them: You know,
either you pay or we sue you for this. So they
pay.
But with the other girls, I would always
say, you are going to do this job, we're
responsible to pay you for the job. Whatever you
want to do after is not our concern. That is up
to you. You're already old enough to do what
you're going to do. So that's why I believe most
of the models are not saying anything because what
they going to do? You know, like, they were not
stupid.
Q.
I'm more concerned with the girls who
were staying at the 301 East 66th Street
apartments.
A.
You can get all that information from
has all of that. Because III was
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actually the one who was buying everything for
that place and things like that. She -- you know,
if she has all that information, she will give it
to you.
Q.
She would have the first and last names?
A.
Everything.
Q.
And lists and everything?
A.
Everything.
Q.
Okay. So she seems like the right
person to talk to?
A.
Yes. You know, III will give you
details on everything that has to be with New
York. Everything related to New York, III will
give it to you.
Q•
Other than that, your recommendation is
to talk to Khalid?
A.
Talk to Khalid. Talk to Amanda.
Q.
Amanda Grant?
A.
Amanda will tell you a lot of things.
Q.
And she is here?
A.
She's in Miami. Yeah, she's in Miami.
Q.
If I find
, will she
talk?
A.
You can try.
Q•
I mean, she is obviously someone who
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knows, right?
A.
Yeah, you can try.
Q.
I mean, you know her as a person.
A.
Yes.
Q.
So is she somebody who seems like
would --
A.
If you start saying that she can make a
lot of money, she will talk. That's it. That's
the only way you're going to get what you want.
Q.
That's the only reason why anybody is
going to talk?
A.
Yeah. You have to start -- if you don't
start with that, nobody is going to open their
mouth. Why? For what? They have to know that if
they're going to open their mouth, they're going
to get something for their words. If everybody
start knowing that they will be able to make
money, you're not going to have one; you're going
to have hundreds. You know, if -- if -- talk to
III. Ask III. And, you know, give me a call
later. And if you want, give you the name of
people in Brazil that you're going to call and
start -- if you start saying, look, if you
cooperate and you tell me everything you know
because, you know, you will be able to make
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$50 million, $20 million, how much you want, let's
find it. If they don't get anything like that,
they're not going to do anything. They're not
going to move a pencil. Because he goes with
$5,000 and they're happy.
Q.
Right.
A.
They're happy.
Q.
Do you know of that happening already?
A.
Yeah. I can say with -- with this
woman, that is probably with
That woman
hate him.
Q.
Hates Jeff Epstein?
A.
No, Jean-Luc. And now she's, like, the
best friend. Jean-Luc never pay her $50,000 he
owe her. And maybe, finally, he pay it and
whatever, and now he has her in his pocket.
Q.
Who else does Jean-Luc stay with when
he's here?
A.
I don't know -- he doesn't stay anymore
in his apartment. He has a house now. He rents a
house. So I know
Q.
In New York?
A.
No, in Miami. In New York, he's still
in the place of Jeffrey Epstein.
Q.
Oh, okay. And down here he stays --
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A.
He used to live in 1100 West Avenue in
the penthouse. Not anymore.
Q.
Other than Jeff Fuller, that's the only
real friend here?
A.
Other than Jeff Fuller. Jeff Fuller is
his partner. You know, Corrado is another friend
of him but I don't know his last name. He lives
here in Miami.
Q•
How do you spell the first name?
A.
C-O-R-R-A-D-O. He's an Italian guy.
That's another person he is very close, very
close, friend of Jean-Luc since Europe. But if
you don't go to him saying about the money,
Corrado is not going to talk. And if you talk to
Corrado about money, believe me, you're not going
to have one; you're going to have 20 names and
you're going to have 20 cases.
Pero, if you don't go with your tool,
which is going to be, okay, we can make money, we
can do this, we can do that, they're not going
to -- they're not go to sell his friend because
they go out with him. Because when they go out
with Jean-Luc, Jean-Luc pays for the bills,
Jean-Luc pays for the gas, Jean-Luc pays for the
vacation, Jean-Luc pays for this and that; even if
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he doesn't have any money to pay his payroll.
Q.
How much time does Jean-Luc spend in
France?
A.
Very little. Very little. He's
traveling all over the world. He's traveling all
over the world.
Q.
And does he have money problems?
A.
Yeah. He doesn't have any money.
Q.
He doesn't?
A.
Jean-Luc doesn't have any money.
Q.
Where does he get the money from, then?
A.
From the company. First you have to pay
Jean-Luc's credit cards and expenses before you
pay anybody else.
Q.
That's the rules?
A.
Yeah. He's -- his American Express
comes for $50,000. Of course, maybe 20 are
tickets for the models, that they going to be
reimbursed by the client, but 30,000 are his
expenses. And he says, no, that's scouting. So
we have to pay for that.
Q.
Okay. Who are the other scouts for MC
Squared?
A.
Khalid was one. Jeff Fuller is another
one. There is another woman,
What's
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her name? Something like that, is her name. I
don't recall her name. She does the scouting,
too.
Q.
Okay.
A.
In New York he had another scouter. A
Jewish guy. But now he has the office of MC
Squared in Tel Aviv. You can talk to him, too. I
don't recall his name. But it's in the Web page
of MC Squared.
Q.
Okay. Yeah, but he's Jean-Luc's friend,
right?
A.
Yeah, but money talks.
Q.
Are there any of the other modeling
agencies that are not friendly with MC Squared?
Such as Ford Modeling Agency; is that someone?
A.
There is a guy in New York that you have
to talk to.
Q.
Who is that?
A.
Uh, what his name? What his name?
Jean-Luc sue him and then he sue him and he won,
because Jean-Luc never paid two girls. And he was
the -- the general manager of New York. And he
opened his own agency and he did much better than
Jean-Luc.
Q.
Do you remember the name of the agency?
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A.
It's one -- can be One Model.
Q.
One?
A.
Yeah. It's Scott. That's his name,
Scott and One Management. If there is a person
that is going to talk everything for Jean-Luc,
it's going to be him.
Q.
And have you seen pictures of Jean-Luc
and underage girls in any other context other than
at model shoots, parties or whatever?
A.
Parties, yeah. There were pictures. He
has pictures in his Facebook with the girls,
hugging the girls or whatever.
Q•
Right. Any with Jeffrey Epstein?
A.
No. I don't think so.
Q•
Have you ever seen any pictures with
Jeffrey Epstein and the models?
A.
The ones that he took at the party.
Q•
Do you know where those are?
A.
No. In Jean-Luc's computer.
Q•
Okay. Has Jean-Luc ever talked about
any of the cases involving Jeffrey Epstein?
A.
Never.
Q.
To you or anybody else that you know?
A.
No, not that I know.
MR. EDWARDS: All right. I'm going
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to be in touch, maybe with the trial
subpoena. Hopefully we can just tell
you that it's off, if things are off.
If it's on, then I'll let you know. But
you can just call my office and I'll
tell you.
THE WITNESS: Okay. But I'm going
to call you --
MR. EDWARDS: All of the Federal
trial subpoenas tell you that you have
to be there on that day. But you can
just call me and I'll tell you whether
you really have to be there or you
don't.
THE WITNESS: This is July 19.
MR. EDWARDS: Right.
THE WITNESS: This is for which
one?
MR. EDWARDS: It's just one of the
very many Jane Does.
THE WITNESS: And this is another
subpoena?
MR. EDWARDS: It's for trial.
MR. FISTEN: It's just for trial.
(Thereupon, the Sworn Statement was
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concluded at 5:23 p.m.)
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)
I, the undersigned authority, certify that
personally appeared before me and
was duly sworn.
WITNESS my hand and official seal this 24th
day of June, 2010.
ELAINE CRANDALL
Notary Public - State of Florida
My Commission No. DD710458
Expires: December 28, 2011
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: SS.
I, ELAINE CRANDALL, Registered Professional
Reporter and Notary Public in and for the State of
Florida at Large, do hereby certif that I
reported the Sworn Statement of
, a
witness called in the above-styled cause; and that
the foregoing pages, numbered from 1 to 74,
inclusive, constitute a true and correct
transcription of my shorthand report of the
deposition by said witness.
I further certify that I am not an attorney
or counsel of any of the parties, nor a relative
or employee of any attorney or counsel connected
with the action, nor financially interested in the
action.
WITNESS my hand and official seal in the City
of Miami, County of Miami-Dade, State of Florida,
this 24th day of June, 2010.
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airplane 47:23
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alcohol 19:23
allow 29:8
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appreciate 34:17
approximately
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arrange 34:1
arrangements
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artists 42:11
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asking 21:17
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balance 32:1
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belong 9:6
belongs 7:18
benefits 12:17
best 18:19,22
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better 35:3
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big 22:5 23:25
billing 35:10
bills 68:23
black 18:17
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blood41:7 43:5
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boyfriends 51:19
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call 11:6 26:13
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capacity 37:8
car 16:16
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case 1:2 5:1
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changing 54:1
characters 44:25
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clearly 54:25
client 69:19
clients 53:7
close 43:2 68:11
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cocaine 19: 15,19
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coke 31:1
collecting 30:4
Colombia 46:8
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comment 22:1
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completely 46:19
computer 18:10
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concluded 73:1
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documentation
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doing 10:8,9
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dollars10:5
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drive 16:19
driving16:16
drove 16:11
drug19:14
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duly 3:4 74:10
Dury 48:6
ears 57:18
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East 7:22 9:3
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easy 39:24
Ecuador 22:2,5,8
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either 17:16
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Elaine1:17 6:25
74:15 75:8,21
icity 8:12
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Emmy 46:25
euployee15:1
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entire 29:13
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U.S. Legal Support
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